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8/12/2019 Disclosures Formats Sep 13
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LL H B D B NK
Table DF – 1 Scope of Application
Position as on 30.09.2013
Qualitative Disclosures
a) The name of the top Bank in thegroup to which the frameworkapplies.
b) An outline of differences in thebasis of consolidation foraccounting and regulatorypurposes, with a briefdescription of the entities withinthe group
i) that are fully consolidated;ii) that are pro-rata
consolidate;iii) that are given a deduction
treatment; andiv) That are neither
consolidated nor deducted(e.g. where the investmentis risk-weighted).
a) The framework of disclosures applies to Allahabad Bank,which is the top Bank in the group.
b) The Bank’s subsidiary /Associates and Joint venture are asunder:
Subsidiary:
Name of Subsidiary
The Bank has one subsidiary as under:
Country ofIncorporation
Ownership(%)
All Bank Finance India 100%
Associates
Name of Banks
: One Regional Rural Bank sponsored by the Bank isas under.
Country ofIncorporation
Ownership(%)
Allahabad UP Gramin Bank* India 35%
* Our two erstwhile RRBs in the state of UP, namely LucknowKshetriya Gramin Bank and Triveni Kshetriya Gramin Bank haveceased to exist and a new amalgamated RRB, i.e., AllahabadUP Gramin Bank has come into existence w.e.f. 02.03.2010.
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LL H B D B NK
Table DF – 5Credit Risk Mitigation: Disclosures
for Standardised Approaches
Position as on 30.09.2013
Qualitative Disclosures
1. A comprehensive policy on valuation of property, plant & machinery, has been approved by the
Board.
2. The collaterals commonly used by the Bank as the risk mitigants comprise of the financial
collaterals (i.e., Bank deposits, govt./postal securities, life insurance policies, gold jewellery, units ofmutual funds etc.), various categories of movable and immovable assets/landed properties etc.
3. Where personal/corporate guarantee is considered necessary, the guarantee is preferably that of
the principal members of the group holding shares in the borrowing company/ flagship Group
Company of corporate. It is ensured that their estimated net worth is substantial enough for them to
stand as guarantors.
4. In line with the regulatory requirements, the Bank has put in place a well-articulated Policy on Credit
Risk Mitigation and Collateral Management duly approved by the Bank’s Board.5. As advised by RBI, the Bank has adopted the comprehensive approach relating to credit risk
mitigation under Standardised Approach, which allows fuller offset of eligible securities against
exposures, by effectively reducing the exposure amount by the value ascribed to the securities.
Thus the eligible financial collaterals have been used to reduce the credit exposure in computation
of credit risk capital. In doing so, the Bank has recognised specific securities namely (a) Bank
Deposits (b) Life Insurance Policies (c) NSCs / KVPs (d) Government Securities, in line with the
RBI guidelines on the matter.6. Besides, other approved forms of credit risk mitigation are “On Balance Sheet Netting” and
availability of “Eligible Guarantees”. On balance sheet netting has been reckoned to the extent of
the deposits available against the loans/advances of the borrower (to the extent of exposure) as per
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LL H B D B NK
Table DF – 6
Securitisation: Disclosure for
Standardised Approach Qualitative
Disclosures
Position as on 30.09.2013
Qualitative Disclosures
(a) The general qualitative disclosurerequirement with respect to
securitisation, including a discussion of:
• the Bank's objectives in relation tosecuritisation activity, including theextent to which these activitiestransfer credit risk of theunderlying securitised exposuresaway from the Bank to other
entities;• the nature of other risks (e.g.,
liquidity risk) inherent insecuritized assets
• the various roles played by theBank in the securitization process(e.g., originator, investor, servicer,provider of credit enhancement,liquidity provider) and an
indication of the extent of theBank’s involvement in each ofthem
• a description of the process in
No securitization during the half-year ended30.09.2013.
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LL H B D B NKtreated as sales or financings
• Methods and key assumptions(including inputs) applied invaluing positions retained orpurchased
• Changes in methods and keyassumptions from the previousperiod and impact of the changes
• Policies for recognizing liabilitieson the balance sheet forarrangements that could requirethe Bank to provide financialsupport for securitised assets.
(c) In the Banking book, the names ofECAIs used for securitisations and thetypes of securitisation exposure forwhich each agency is used. Not applicable.
SL
NoQuantitative Disclosures: Banking Book
(Amount Rs. in Crores)
(d) The total amount of exposures securitised by the Bank(e) For exposures securitized, losses recognised by the Bank
during the current period broken down by exposure type (e.g.,
credit cards, housing loans, auto loans, etc. detailed by
underlying security)
(f) Amount of assets intended to be securitized within a year
(g) Of (f), amount of assets originated within a year
(h) Total amount of exposures securitized (by exposure type) andunrecognized gain or losses on sale by exposure type.
(i) Aggregate amount of:
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LL H B D B NK
Table DF – 7 Market Risk in Trading Book
Position as on 30.09.2013
Qualitative disclosures
(a) Market Risk:
1. Market Risk is defined as the possibility of loss caused by changes/movements in the market
variables such as interest rates, foreign currency exchange rates, equity prices and commodity
prices. Bank’s exposure to Market risk arises from investments (interest related instruments and
equities) in trading book (both AFS and HFT categories) and the Foreign Exchange positions.
The objective of the market risk management is to minimize the impact of losses on earningsand equity.
2. The Bank has put in place Board approved Policies on Investments, Foreign Exchange
Operations, Trading in Forex Market, Derivatives, Asset Liability Management and Stress
Testing for effective management of market risk. The policies ensure that operations in fixed
income securities, equities, foreign exchange and derivatives are conducted in accordance with
sound business practices and as per extant regulatory guidelines.
3. Bank uses ‘Cash-flow Approach’ and ‘Stock Approach’ for measuring, monitoring and managingLiquidity Risk. Under cash flow approach, mismatches under various time buckets are analyzed
vis-à-vis tolerance limits. Under stock approach, various ratios like Liquid Assets to Total
Assets, Purchased Funds to Liquid Assets, Loans to Core Deposits etc. are calculated and
analyzed against tolerance limits specified in the ALM Policy. Appropriate corrective measures,
wherever required are taken as per directives of ALCO / Board. The Bank has also put in place
mechanism for Contingency Funding Plan to assess the projected liquidity position of the Bank
under stressed scenarios.4. Interest Rate Risk is managed through use of Gap analysis of rate sensitive assets and
liabilities and monitored through prudential tolerance limits. Bank uses Traditional Gap Analysis
(TGA) for assessing the impact of Interest Rate Risk on its Net Interest Income over a short
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LL H B D B NK
Table DF – 8 Operational Risk
Position as on 30.09.2013
Qualitative disclosures
1. Operational Risk is the risk of loss resulting from inadequate or failed internal processes, people
and systems or from external events. Operational risk includes legal risk but excludes strategic
and reputation risks.
2. The Bank has framed Operational Risk Management Policy duly approved by the Board.
Supporting policies adopted by the Board which deal with management of various areas of
operational risk are (a) Compliance Risk Management Policy (b) Forex Risk Management Policy
(c) Policy Document on Know Your Customers (KYC) and Anti Money Laundering (AML)
Procedures (d) Business Continuity and Disaster Recovery Policy (e) Fraud Risk Management
Policy etc.
3. The Operational Risk Management Policy adopted by the Bank outlines organization structure anddetailed processes for management of operational risk. The basic objective of the policy is to
closely integrate operational risk management system into the day-to-day risk management
processes of the Bank by clearly assigning roles for effectively identifying, assessing, monitoring
and controlling / mitigating operational risks and by timely reporting of operational risk exposures,
including material operational losses. Operational risks in the Bank are managed through
comprehensive and well articulated internal control frameworks.
4. In line with the final guidelines issued by RBI, the Bank has adopted the Basic Indicator
Approach for computing capital for Operational Risk.
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LL H B D B NK
Table DF – 9Interest Rate Risk in the
Banking Book (IRRBB)
Position as on 30.09.2013
Qualitative disclosures
(a) Interest Rate Risk in the Banking Book:
1. Interest Rate Risk is the risk where changes in market interest rates might adversely affect a
Bank’s financial condition. The immediate impact of changes in interest rates is on Bank’s earnings
i.e.
Net Interest Income (NII). A long -term impact of changing interest rates is on Bank’s Market Value
of Equity (MVE) or Net Worth as the economic value of Bank’s assets, liabilities and off-balance
sheet positions get affected due to variation in market interest rates.
2. The impact on income (Earnings perspective) is measured through use of Traditional Gap analysis,
which measures mismatch between rate sensitive liabilities and rate sensitive assets (including off-
balance sheet positions) over different time intervals, as at a given date. The impact of interest rate
risk on NII is assessed by applying notional rate shock of 100,200 & 300 bps on gaps in various
time bucket up to a period of one year as prescribed in Bank’s ALM Policy.
3. The Bank has adopted Duration Gap Analysis (DGA) to measure interest rate risk in its balance
sheet from the economic value perspective. The Bank computes bucket-wise Modified Duration of
Rate sensitive Liabilities and Assets using the suggested common maturity, coupon and yield
parameters, prescribed by RBI/ALCO. The modified Duration Gap is computed from weighted
average modified duration of total rate sensitive assets and rate sensitive liabilities. The impact of
change in interest rate on net worth is analyzed by applying a notional interest rate shock of100,
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LL H B D B NK
Table DF – 11 Composition of Capital
Position as on 30.09.2013
(Rs. in million)
Particular Amount
Amounts
Subject To
Pre-Basel III
Treatment
Ref No.
Common Equity Tier 1 capital: instruments and reserves
1Directly issued qualifying common share capital plus related
stock surplus (share premium)22961.05
A1 +
A2
2 Retained earnings 80825.31
B1 +
B2+ B3+B4
3 Accumulated other comprehensive income (and other reserves) -
4Directly issued capital subject to phase out from CET1 (only
applicable to non-joint stock companies1)-
Public sector capital injections grandfathered until 1 January
2018-
5Common share capital issued by subsidiaries and held by third
parties (amount allowed in group CET1)-
6 C E it Ti 1 it l b f l t dj t t 103786 36
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LL H B D B NK15 Defined-benefit pension fund net assets 0.00
16Investments in own shares (if not already netted off paid-in
capital on reported balance sheet)0.00
17 Reciprocal cross-holdings in common equity 20.16 100.82
18
Investments in the capital of Banking, financial and insurance
entities that are outside the scope of regulatory consolidation, net
of eligible short positions, where the Bank does not own more
than 10% of the issued share capital (amount above 10%
threshold)
0.00
19
Significant investments in the common stock of Banking,
financial and insurance entities that are outside the scope of
regulatory consolidation, net of eligible short positions (amount
above 10% threshold)
0.00
20 Mortgage servicing rights (amount above 10% threshold) 0.00
21Deferred tax assets arising from temporary differences (amount
above 10% threshold, net of related tax liability)0.00
22 Amount exceeding the 15% threshold 0.00
23of which: significant investments in the common stock of
financials0.00
24 of which: mortgage servicing rights 0.00
25 of which: deferred tax assets arising from temporary differences 0.00
26 National specific regulatory adjustments (26a+26b+26c+26d) 2989.60
26a Of which: Investments in the equity capital of unconsolidatednon-financial subsidiaries
0.00
26bOf which: Investment in the equity capital of unconsolidated non-
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LL H B D B NKAdditional Tier 1 capital: instruments
30Directly issued qualifying Additional Tier 1 instruments plus
related stock surplus (31+32)2700.00
31 of which: classified as equity under applicable accountingstandards (Perpetual Non-Cumulative Preference Shares)
0.00
32of which: classified as liabilities under applicable accounting
standards (Perpetual debt Instruments)2700.00 C1
33Directly issued capital instruments subject to phase out from
Additional Tier 10.00
34
Additional Tier 1 instruments (and CET1 instruments not
included in row 5) issued by subsidiaries and held by third parties
(amount allowed in group AT1)
0.00
35 of which: instruments issued by subsidiaries subject to phase out 0.00
36 Additional Tier 1 capital before regulatory adjustments 2700.00
Additional Tier 1 capital: regulatory adjustments
37 Investments in own Additional Tier 1 instruments 0.00
38 Reciprocal cross-holdings in Additional Tier 1 instruments 1.00 5.00
39
Investments in the capital of Banking, financial and insurance
entities that are outside the scope of regulatory consolidation, net
of eligible short positions ,where the Bank does not own more
than 10% of the issued common share capital of the entity
(amount above 10% threshold)
0.00
40
Significant investments in the capital of Banking, financial and
insurance entities that are outside the scope of regulatory 0.00
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LL H B D B NK43 Total regulatory adjustments to Additional Tier 1 capital 147.70
44 Additional Tier 1 capital (AT1) 2552.30
44a Additional Tier 1 capital reckoned for capital adequacy 2552.30
45 Tier 1 capital (T1 = CET1 + AT1) (row 29 + row 44a) 103255.55
Tier 2 capital: instruments and reserves
46Directly issued qualifying Tier 2 instruments plus related stock
surplus0.00
47Directly issued capital instruments subject to phase out from Tier
2
24747.60 C2+ C3
48
Tier 2 instruments (and CET1 and AT1 instruments not included
in rows 5 or 34) issued by subsidiaries and held by third parties
(amount allowed in group Tier 2)
0.00
49 of which: instruments issued by subsidiaries subject to phase out 0.00
50 Provisions 13160.96 D1+ D2
51 Tier 2 capital before regulatory adjustments 37908.56
Tier 2 capital: regulatory adjustments
52 Investments in own Tier 2 instruments 0.00
53 Reciprocal cross-holdings in Tier 2 instruments 87.31 436.54
54
Investments in the capital of Banking, financial and insurance
entities that are outside the scope of regulatory consolidation, netof eligible short positions, where the Bank does not own more
than 10% of the issued common share capital of the entity
( b h 10% h h ld)
0.00
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LL H B D B NK57 Total regulatory adjustments to Tier 2 capital 234.01
58 Tier 2 capital (T2) 37674.55
58a Tier 2 capital reckoned for capital adequacy 37674.55
58b Excess Additional Tier 1 capital reckoned as Tier 2 capital 0.00
58cTotal Tier 2 capital admissible for capital adequacy (row 58a
+ row 58b)37674.55
59 Total capital (TC = T1 + T2) (row 45+row 58c) 140930.10
RISK WEIGHTED ASSETS IN RESPECT OF AMOUNTS
SUBJECT TO PRE-BASEL III TREATMENT
16825.00
60 Total risk weighted assets (row 60a +row 60b +row 60c) 1314343.56
60a of which: total credit risk weighted assets 1168116.44
60b of which: total market risk weighted assets 45602.90
60c of which: total operational risk weighted assets 100624.22
Capital ratios
61Common Equity Tier 1 (as a percentage of risk weighted
assets)7.66%
62 Tier 1 (as a percentage of risk weighted assets) 7.86%
63 Total capital (as a percentage of risk weighted assets) 10.72%
64
Institution specific buffer requirement (minimum CET1
requirement plus capital conservation and countercyclical
buffer requirements, expressed as a percentage of risk
i ht d t )
4.5%
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LL H B D B NKAmounts below the thresholds for deduction (before risk weighting)
72 Non-significant investments in the capital of other financials 0.00
73 Significant investments in the common stock of financials 0.00
74 Mortgage servicing rights (net of related tax liability) 0.00
75Deferred tax assets arising from temporary differences (net of
related tax liability)0.00
Applicable caps on the inclusion of provisions in Tier 2
76Provisions eligible for inclusion in Tier 2 in respect of exposures
subject to standardised approach (prior to application of cap)13160.96
77Cap on inclusion of provisions in Tier 2 under standardised
approach14601.46
78
Provisions eligible for inclusion in Tier 2 in respect of exposures
subject to internal ratings-based approach (prior to application of
cap)
NA
79Cap for inclusion of provisions in Tier 2 under internal ratings-
based approach NA
Capital instruments subject to phase-out arrangements (only applicable between March 31, 2017 and March 31,
2021)
80Current cap on CET1 instruments subject to phase out
arrangements NA
81Amount excluded from CET1 due to cap (excess over cap after
redemptions and maturities) NA
82Current cap on AT1 instruments subject to phase out
arrangements NA
Amount excluded from AT1 due to cap (excess over cap after
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LL H B D B NKOf which: Subordinated Debt – Tier II Capital 24119 C3
iv. Other liabilities & provisions 42589.75 -
Total 2085972.93
B. Assets
i.Cash and balances with Reserve Bank of India 88397.29 -
Balance with Banks and money at call and short notice 76382.01 -
ii.
Investments: 561553.08 -
of which: Government securities 464719.43 -
of which: Other approved securities 455.81 -
of which: Shares 4275.59 -
of which: Debentures & Bonds 35514.63 -
of which: Subsidiaries / Joint Ventures / Associates 1512.75 -
of which: Others (Commercial Papers, Mutual Funds etc.) 5507.49 -
iii.
Loans and advances 13189557.27 -
of which: Loans and advances to Banks -
of which: Loans and advances to customers -
iv. Fixed assets 12809.01 -
v.
Other assets 27874.27 -
of which: Goodwill and intangible assets 0.00 -
of which: Deferred tax assets 0.00 -
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LL H B D B NKS. No. Parti culars Equity
32 If write-down, full or partial NA
33 If write-down, permanent or temporary NA
34 If temporary write-down, description of write-up
mechanism
NA
35 Position in subordination hierarchy in liquidation (specifyinstrument type immediately senior to instrument)
NA
36 Non-compliant transitioned features No
37 If yes, specify non-compliant features NA
B. Tier I capital instruments
The main features of Tier I Capital Instruments are as follows:
S.No.
Parti culars Tier I series I Tier I Series II
1 Issuer Allahabad Bank Allahabad Bank
2 Unique identifier (e.g. CUSIP, ISIN orBloomberg identifier for private
placement)
INE428A09091 INE428A09125
3 Governing law(s) of the instrument Indian Laws Indian Laws
Regulatory treatment
4 Transitional Basel III rules Additional Tier 1 Additional Tier I
5 Post-transitional Basel III rules Ineligible Ineligible
6 Eligible at solo/group/ group & solo Solo & Group Solo & Group
7 Instrument type Perpetual Perpetual
8 Amount recognised in regulatory capital(` in million, as of most recent reportingdate)
Rs 1350 million Rs 1350 million
9 P l f i t t R 1 illi B d R 1 illi B d
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LL H B D B NKNo.
18 Coupon rate and any related index 9.20% p.a. payable annuallyfrom issue date till the firstcall option date and if theBank does not exercise thecall option, 50 bps over andabove coupon rate of 9.20%i.e. 9.70 % p.a. after 30thmarch, 2019
9.08% p.a., payable annuallyfrom issue date till first calloption date and if the Bankdoes not exercise the calloption, 50 bps over and abovecoupon rate of 9.08% i.e.9.58% p.a. after 18thDecember, 2019
19 Existence of a dividend stopper No No
20 Fully discretionary, partially discretionaryor mandatory
Partially discretionary Partially discretionary
21 Existence of step up or other incentive to
redeem
Yes Yes
22 Noncumulative or cumulative Non-cumulative Non-cumulative
23 Convertible or non-convertible Non-Convertible Non-Convertible
24 If convertible, conversion trigger(s) NA NA
25 If convertible, fully or partially NA NA
26 If convertible, conversion rate NA NA
27 If convertible, mandatory or optional
conversion
NA NA
28 If convertible, specify instrument typeconvertible into
NA NA
29 If convertible, specify issuer of instrumentit converts into
NA NA
30 Write-down feature No No
31 If write-down, write-down trigger(s) NA NA
32 If write-down, full or partial NA NA
33 If write-down, permanent or temporary NA NA34 If temporary write-down, description of
write-up mechanismNA NA
35 Position in subordination hierarchy in The claims of the The claims of the Bondholders
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LL H B D B NKC. Tier II Capital Instruments
a. Upper Tier II capital Instruments
The main features of Upper Tier II Capital Instruments are as follows:
S. No. Parti culars Series I Series II
1. Issuer Allahabad Bank Allahabad Bank
2.
Unique identifier (e.g. CUSIP,ISIN or Bloomberg identifier forprivate placement)
INE428A09075 INE428A09117
3.Governing law(s) of theinstrument
Indian Laws Indian Laws
Regulatory treatment
4. Transitional Basel III rules Tier 2
5. Post-transitional Basel III rules Ineligible
6.Eligible at solo/group/ group &solo Solo & Group
7. Instrument type Upper Tier II
8.
Amount recognised in regulatorycapital (` in million, as of mostrecent reporting date)
Rs 4500 million Rs 4500 million
9. Par value of instrument Rs 1 million per Bond Rs 1 million per Bond
10. Accounting classification Liability
11. Original date of issuance 19th march 2009 18th December 2009
12. Perpetual or dated Dated13. Original maturity date 19th March 2024 18th December 2024
14.Issuer call subject to priorsupervisory approval
Yes
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LL H B D B NKS. No. Parti culars Series I Series II
20.Fully discretionary, partiallydiscretionary or mandatory
Partially discretionary Partially discretionary
21.Existence of step up or otherincentive to redeem
Yes
22. Noncumulative or cumulative Non-Cumulative Non-Cumulative
23. Convertible or non-convertible Non-Convertible Non-Convertible
24.If convertible, conversiontrigger(s)
NA NA
25. If convertible, fully or partially NA NA
26. If convertible, conversion rate NA NA
27.If convertible, mandatory or
optional conversion
NA NA
28.If convertible, specify instrumenttype convertible into
NA NA
29.If convertible, specify issuer ofinstrument it converts into
NA NA
30. Write-down feature No No
31.If write-down, write-downtrigger(s)
NA NA
32. If write-down, full or partial NA NA33.
If write-down, permanent ortemporary
NA NA
34.If temporary write-down,description of write-upmechanism
NA NA
35.
Position in subordinationhierarchy in liquidation (specifyinstrument type immediatelysenior to instrument)
The claims of the investors inthese Bonds shall be (a) superiorto the claims of investors ininstruments eligible for inclusionin Tier I capital; and (b)subordinate to the claims of allth dit
The claims of the investors inthese Bonds shall be (a) superiorto the claims of investors ininstruments eligible for inclusion inTier I capital; and (b) subordinateto the claims of all other creditors.
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LL H B D B NK
BASEL III DISCLOSURES – SEP’2013 Page 24 of 25
b. Subordinate Bonds
The main features of Subordinate Bonds are as follows:
S. No. Particu lars Series V Series VI Series VII Series VIII Series IX1. Issuer Allahabad Bank Allahabad Bank Allahabad Bank Allahabad Bank Allahabad Bank
2.Unique identifier (e.g. CUSIP, ISIN orBloomberg identifier for privateplacement)
INE428A09042 INE428A09059 INE428A09067 INE428A09083 INE428A09109
3. Governing law(s) of the instrument Indian Laws Indian Laws Indian Laws Indian Laws Indian Laws
Regulatory treatment
4. Transitional Basel III rules Tier 25. Post-transitional Basel III rules Ineligible
6. Eligible at solo/group/ group & solo Solo & Group
7. Instrument type Tier 2 Instruments
8. Amount recognised in regulatory capital (`in million, as of most recent reportingdate)
Rs 2000 million Rs 2247.60million
Rs 3000 million Rs 4000 million Rs 4500 million
9.Par value of instrument Rs 1 million per
Bond Rs 1 million perBond
Rs 1 million perBond
Rs 1 million perBond
Rs 1 million perBond
10. Accounting classification Liability
11.Original date of issuance 13th march 2006 29th September
200625th September2007
26th March 2009 4th August 2009
12. Perpetual or dated Dated
13.
Original maturity date 13th march 2016 29th September
2016
25th September
2017
26th March 2019 4th August 2019
14.Issuer call subject to prior supervisoryapproval
No
15.Optional call date, contingent call datesand redemption amount
No
16. Subsequent call dates, if applicable NA
Coupons / dividends17. Fixed or floating dividend / coupon Fixed
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LL H B D B NK
BASEL III DISCLOSURES – SEP’2013 Page 25 of 25
S. No. Particu lars Series V Series VI Series VII Series VIII Series IX
18.Coupon rate and any related index 8.00% p.a.
payable semi-annually
8.85% p.a.payable annually
10.00% p.a.payable annually
9.23% p.a.payable annually
8.45% p.a.payable annually
19. Existence of a dividend stopper No
20.Fully discretionary, partially discretionaryor mandatory
Partially discretionary
21.Existence of step up or other incentive toredeem
Yes
22. Noncumulative or cumulative Non-Cumulative23. Convertible or non-convertible Non-Convertible
24. If convertible, conversion trigger(s) NA25. If convertible, fully or partially NA
26. If convertible, conversion rate NA
27. If convertible, mandatory or optionalconversion
NA
28.If convertible, specify instrument typeconvertible into
NA
29.If convertible, specify issuer of instrumentit converts into
NA
30. Write-down feature No
31. If write-down, write-down trigger(s) NA
32. If write-down, full or partial NA33. If write-down, permanent or temporary NA
34.
If temporary write-down, description of
write-up mechanism NA
35.Position in subordination hierarchy inliquidation (specify instrument typeimmediately senior to instrument)
36. Non-compliant transitioned features Yes
37. If yes, specify non-compliant features No Basel III Loss Absorbency